On November 21, 2025, the European Commission officially published Delegated Directive (EU) 2025/2364 in the Official Journal of the European Union.
As the exemption entries for the use of lead (Pb) alloys in electrical and electronic equipment (EEE) have been comprehensively revised under RoHS Annex III, we highly recommend that companies exporting relevant materials and components proactively review these regulatory changes to ensure continuous compliance.
Overview
Through two comprehensive scientific and technical assessments, the EU has adjusted the expiration dates of existing exemption entries by category and introduced necessary new sub-entries.
The Directive enters into force on December 11, 2025. Member States must complete transposition into national law by June 30, 2026, with practical application taking effect on July 1, 2026.
Key Takeaways
1. Core Highlights by Material
Steel: Purpose Segmentation and Stricter Management
The exemption for machining steel is maintained, as finding reliable lead substitutes remains technically challenging.
However, the application scope has been segmented, splitting the existing entry 6(a)-I into two distinct sub-entries:
Aluminum: Phase-out and Enhanced Thresholds
As reliable substitutes are now available, the exemption for machining aluminum (6(b)-II) will be phased out, granting an 18-month transition period for the industry to adapt.
A new entry, 6(b)-III, has been established for cast alloys derived from recycled lead-bearing aluminum scrap, with the maximum permissible lead concentration strictly set at 0.3%.
For complex industrial equipment requiring extensive redesign (Categories 9 and 11), longer validity periods have been granted in consideration of industry circumstances.
Copper: Current Exemption Maintained
2. Exemption Expiration Dates by Entry
Exemption Entry
| Description
| Expiration Date
|
|---|
6(a) | Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% lead by weight | December 11, 2026 |
6(a)-I | Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight | June 30, 2027 |
6(a)-II (New) | Lead in batch hot dip galvanized steel components containing up to 0.2% lead by weight | June 30, 2027 |
6(b) | Lead as an alloying element in aluminum containing up to 0.4% lead by weight | June 11, 2027 |
6(b)-I | Lead as an alloying element in aluminum alloys derived from recycling of lead-bearing aluminum scrap containing up to 0.4% lead by weight | Cat 1~7, 10: December 11, 2026 Cat 9, 11: June 30, 2027 |
6(b)-II | Lead as an alloying element in aluminum for machining purposes containing up to 0.4% lead by weight | Cat 1~7, 10: June 11, 2027 Cat 9, 11: June 30, 2027 |
6(b)-III (New) | Lead as an alloying element in cast alloys derived from recycling of lead-bearing aluminum scrap containing up to 0.3% lead by weight | Cat 1~8, 9 (excluding industrial monitoring & control instruments), 10 : June 30, 2027 |
6(c) | Copper alloy containing up to 4% lead by weight | June 30, 2027 |
*RoHS Electrical and Electronic Equipment (EEE) Categories
Category 1: Large household appliances (e.g., refrigerators, washing machines)
Category 2: Small household appliances (e.g., vacuum cleaners, irons)
Category 3: IT and telecommunications equipment (e.g., laptops, printers, mobile phones)
Category 4: Consumer equipment (e.g., TVs, audio systems)
Category 5: Lighting equipment
Category 6: Electrical and electronic tools
Category 7: Toys, leisure, and sports equipment
Category 8: Medical devices (including in vitro diagnostic medical devices)
Category 9: Monitoring and control instruments
Category 10: Automatic dispensers
Category 11: Other EEE not covered by any of the categories above
3. New Child Safety Footnote (*) Conditions
A child safety condition footnote (*) has been applied to all marked exemption entries. This measure is intended to align the protection level with REACH (Regulation (EC) No 1907/2006) Annex XVII, Entry 63, Paragraph 7.
The newly established conditions are as follows:
Electronic products with any dimension smaller than 5 cm, or containing detachable protruding parts of that size, are deemed accessible to children (can be placed in the mouth).
In principle, lead exemptions shall not apply to such products if they are supplied to the general public.
However, the exemption may be granted if it is proven that the lead release rate does not exceed 0.05 μg/cm² per hour.
For coated articles, manufacturers must demonstrate that this release rate threshold is maintained for a period of at least two years of normal use.
Conclusion
Delegated Directive (EU) 2025/2364 is a significant revision that subdivides the lead alloy exemption structure of RoHS Annex III into entry and category levels, subsequently resetting their expiration dates.
Most exemption entries will reach their final deadline on June 30, 2027, with practical enforcement beginning July 1, 2026. We strongly advise compliance officers to thoroughly review the phase-out schedule for machining aluminum (6(b)-II) and assess the applicability of the new child safety footnote (*) conditions to your product portfolios.
[References & Links]
On November 21, 2025, the European Commission officially published Delegated Directive (EU) 2025/2364 in the Official Journal of the European Union.
As the exemption entries for the use of lead (Pb) alloys in electrical and electronic equipment (EEE) have been comprehensively revised under RoHS Annex III, we highly recommend that companies exporting relevant materials and components proactively review these regulatory changes to ensure continuous compliance.
Overview
Through two comprehensive scientific and technical assessments, the EU has adjusted the expiration dates of existing exemption entries by category and introduced necessary new sub-entries.
The Directive enters into force on December 11, 2025. Member States must complete transposition into national law by June 30, 2026, with practical application taking effect on July 1, 2026.
Key Takeaways
1. Core Highlights by Material
Steel: Purpose Segmentation and Stricter Management
The exemption for machining steel is maintained, as finding reliable lead substitutes remains technically challenging.
However, the application scope has been segmented, splitting the existing entry 6(a)-I into two distinct sub-entries:
6(a)-I: Lead in machining steel
6(a)-II: Lead in batch hot dip galvanized steel
Aluminum: Phase-out and Enhanced Thresholds
As reliable substitutes are now available, the exemption for machining aluminum (6(b)-II) will be phased out, granting an 18-month transition period for the industry to adapt.
A new entry, 6(b)-III, has been established for cast alloys derived from recycled lead-bearing aluminum scrap, with the maximum permissible lead concentration strictly set at 0.3%.
For complex industrial equipment requiring extensive redesign (Categories 9 and 11), longer validity periods have been granted in consideration of industry circumstances.
Copper: Current Exemption Maintained
Due to the current lack of viable alternatives, the exemption for copper alloys containing up to 4% lead by weight (6(c)) has been extended until June 30, 2027.
2. Exemption Expiration Dates by Entry
6(a)
Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% lead by weight
December 11, 2026
6(a)-I
Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight
June 30, 2027
6(a)-II (New)
Lead in batch hot dip galvanized steel components containing up to 0.2% lead by weight
June 30, 2027
6(b)
Lead as an alloying element in aluminum containing up to 0.4% lead by weight
June 11, 2027
6(b)-I
Lead as an alloying element in aluminum alloys derived from recycling of lead-bearing aluminum scrap containing up to 0.4% lead by weight
Cat 1~7, 10: December 11, 2026
Cat 9, 11: June 30, 2027
6(b)-II
Lead as an alloying element in aluminum for machining purposes containing up to 0.4% lead by weight
Cat 1~7, 10: June 11, 2027
Cat 9, 11: June 30, 2027
6(b)-III (New)
Lead as an alloying element in cast alloys derived from recycling of lead-bearing aluminum scrap containing up to 0.3% lead by weight
Cat 1~8, 9 (excluding industrial monitoring & control instruments), 10
: June 30, 2027
6(c)
Copper alloy containing up to 4% lead by weight
June 30, 2027
*RoHS Electrical and Electronic Equipment (EEE) Categories
Category 1: Large household appliances (e.g., refrigerators, washing machines)
Category 2: Small household appliances (e.g., vacuum cleaners, irons)
Category 3: IT and telecommunications equipment (e.g., laptops, printers, mobile phones)
Category 4: Consumer equipment (e.g., TVs, audio systems)
Category 5: Lighting equipment
Category 6: Electrical and electronic tools
Category 7: Toys, leisure, and sports equipment
Category 8: Medical devices (including in vitro diagnostic medical devices)
Category 9: Monitoring and control instruments
Category 10: Automatic dispensers
Category 11: Other EEE not covered by any of the categories above
3. New Child Safety Footnote (*) Conditions
A child safety condition footnote (*) has been applied to all marked exemption entries. This measure is intended to align the protection level with REACH (Regulation (EC) No 1907/2006) Annex XVII, Entry 63, Paragraph 7.
The newly established conditions are as follows:
Electronic products with any dimension smaller than 5 cm, or containing detachable protruding parts of that size, are deemed accessible to children (can be placed in the mouth).
In principle, lead exemptions shall not apply to such products if they are supplied to the general public.
However, the exemption may be granted if it is proven that the lead release rate does not exceed 0.05 μg/cm² per hour.
For coated articles, manufacturers must demonstrate that this release rate threshold is maintained for a period of at least two years of normal use.
Conclusion
Delegated Directive (EU) 2025/2364 is a significant revision that subdivides the lead alloy exemption structure of RoHS Annex III into entry and category levels, subsequently resetting their expiration dates.
Most exemption entries will reach their final deadline on June 30, 2027, with practical enforcement beginning July 1, 2026. We strongly advise compliance officers to thoroughly review the phase-out schedule for machining aluminum (6(b)-II) and assess the applicability of the new child safety footnote (*) conditions to your product portfolios.
[References & Links]
https://eur-lex.europa.eu/eli/dir_del/2025/2364/oj
https://eur-lex.europa.eu/eli/dir/2011/65/oj